Lacroix, DJ:

1 Joseph Lorenzo Guay of the City of Montreal died on January 19, 1962. He was president of J L Guay Limitée. He held 43 shares of the J L Guay Limitée construction company. As a matter of fact, he was a minority shareholder, because his son Léon personally held 140 shares of the same company; the very few remaining shares were held by some relatives.

Cattanach, J:

1 These are appeals from a decision of the Tax Review Board which had dismissed the appeals by the plaintiff herein to that Board from the assessments to income tax by the Minister of National Revenue in respect of the plaintiff's income for his 1969, 1970 and 1971 taxation years.

2 In the three taxation years the plaintiff, in computing his income, had deducted farming losses in the respective amounts of $16,288.54, $19,752.62 and $18,576.80.

Addy, J:

Mogan T.C.J.:

Judge K A Flanigan:

The Chairman (orally: December 11, 1974):

1 This is an appeal by Lazare Investments Corporation against the reassessment of the Minister of National Revenue for the 1972 taxation year.

2 The question to be determined is whether or not the appellant company is carrying on an active business under section 125 of the 1972 Act. All the requirements of the section have been complied with and the only issue is whether the appellant carried on an “active business”.

The Assistant Chairman:

1 This is the appeal of Safari Investments Ltd from an income tax assessment in respect of the 1971 taxation year.

The Chairman (orally: April 9, 1975):

1 This is an appeal under the former Estate Tax Act by Swarn Kaur Bains and the Canada Trust Company, executors of the estate of Jogindar Singh Bains, who died on or about October 30, 1970.

2 Probate was granted in the Supreme Court of British Columbia to the aforementioned executors on January 27, 1971.

A W Prociuk (orally: June 13, 1975):

Thurlow, J (concurred in by Mackay, DJ):